In her Second Amended Response to Maxwell’s discovery demands, Virginia Giuffre pushed back aggressively, refusing to yield to Maxwell’s attempts to broaden discovery into intrusive and irrelevant personal and psychological domains. She objected to Maxwell’s sprawling requests as overly burdensome, unduly invasive, and aimed at discrediting her through unnecessary exposure rather than legitimate legal pursuit. Giuffre instead reinforced her focus on evidence directly tied to the defamation claims and trafficking allegations, contesting any effort by Maxwell to turn the process into a fishing expedition or reputation‑smearing exercise under the guise of legal procedure.
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Mark as Played
Transcript
Episode Transcript
Available transcripts are automatically generated. Complete accuracy is not guaranteed.
Speaker 1 (00:00):
What's up everyone, and welcome back to the Epstein Chronicles.
In this episode, we're going to pick right back up
where we left off with the Virginia Roberts' second supplemental
response number eleven. Any document reflecting any confidentiality agreement by
in between or concerning you and the mar A Lago
(00:21):
Club response to Requests number ten. Miss Roberts subjects to
this request to the extent it seeks documents protected by
the attorney client, work product, joint defense, public interest, and
any other applicable privilege. Miss Roberts has been unable to
locate any such documents. Twelve. All documents concerning any employment
(00:43):
by you from nineteen ninety eight to the present, or
identified by you in response to interrogatory number nine, including
any records of your employment at the Roadhouse Grille in
Palm Beach, Florida. Response to Request number twelve. Miss Roberts
objections to this request on the grounds that is overly
broad and unduly burdensome and calls for the production of
(01:05):
documents that are irrelevant to this action and not reasonably
calculated to lead to the discovery of admissible evidence. Miss
Roberts objects to this request to the extent it seeks
documents protected by the attorney client work product, joint defense,
public interest, or any other applicable privilege, subject to and
without waiving the above objections. Miss Roberts has already produced
(01:28):
documents and will produce non privileged documents responsive to this request,
and will continue to supplement this production. Thirteen all documents
concerning any allegations of theft by you from the Roadhouse
Grille in Palm Beach, Florida from nineteen ninety nine to
two thousand and two. Response to Requests number thirteen. Miss
(01:49):
Roberts objects to this request and that it seeks information
solely to harass, embarrass, and intimidate Miss Roberts. Miss Roberts
objects to this request to the extent it seeks docus
mints protected by the attorney client privilege, the attorney work
product privilege, joint defense, common interest privilege, public interest privilege,
and any other applicable privilege. Miss Roberts objects to this
(02:12):
request and that it wrongfully characterizes a theft by you.
Miss Roberts objects to this request as it seeks documents
of sealed juvenile records, and only means of obtaining such
records are either through the court order or illegal means.
Miss Roberts has been unable to locate any such documents.
Fourteen A copy of your federal, state, or local tax
(02:34):
returns for the years nineteen ninety eight to the present,
whether from the United States or any other country. Response
to Request number fourteen. Miss Roberts objections to this request
on the grounds that it is overly broad and unduly burdensome,
and calls for the production of documents that are irrelevant
to this action and not reasonably calculated to lead to
(02:58):
the discovery of admissible vas evidence. Miss Roberts objects to
this request and that it seeks confidential financial information and
that is irrelevant to this action. Miss Roberts objects to
this request and that it seeks financial information from her
when she was a minor child starting at age fourteen.
Miss Roberts objects in that it seeks information protected by
(03:19):
the attorney client privilege, the attorney work product privilege, joint
defense common interest privilege, the account in client privilege, and
any other applicable privilege. Subject to and without waiving the
above objections, Miss Roberts has already produced documents and will
produce non privileged documents responsive to this request and will
continue to supplement its production. Fifteen all documents concerning your
(03:43):
attendance at, or enrollment in any school or educational program
of whatever type from nineteen ninety eight to the present.
Response to Request number fifteen, Miss Roberts objections to this
request on the grounds that it is overly broad and
on duly burdensome, and calls for the production of documents
that are irrelevant to this action and not reasonably calculated
(04:06):
to lead to the discovery of admissible evidence. Miss Roberts
objects to this request to the extent it seeks documents
protected by the attorney client privilege, the attorney work product privilege,
joint defense, common interest privilege, and public interest privilege, and
any other applicable privilege. Miss Roberts objects to this request
in that her school records from when she was a
(04:28):
minor child are an invasion of privacy and sought only
to harass an embarrasser. Subject to and without waiving the
above objections, Miss Roberts has already produced documents and will
produce non privileged documents responsive to this request, and will
continue to supplement its production. Sixteen Any diary, journal or
(04:49):
calendar concerning your activities between nineteen ninety six and two
thousand and two response to Requests Number sixteen. Miss Roberts
objection to this request on the grounds that the time
period is overly broad and calls for the production of
documents that are irrelevant to this action and not reasonably
calculated to lead to the discovery of admissible evidence. Miss
(05:13):
Roberts objects to this request to the extent it seeks
proprietary and copyrighted protected materials. Miss Roberts subjects in that
it seeks information protected by the attorney client privilege, the
attorney work product privilege, joint defense common interest privilege, and
any other applicable privilege. Miss Roberts objects to this request
(05:33):
in that it seeks highly personal and sensitive material from
a time when she was being sexually trafficked. Miss Roberts
has been unable to locate any such documents. Seventeen. All
documents relating to your travel from the period of nineteen
ninety eight to the present, including but not limited to,
a copy of your passport that was valid for any
(05:54):
part of that time period, any visa issue to you
for travel, any visa application that you prepare or which
was prepared on your behalf and travel itinerary receipt log
or document, including any photograph substantiating your travel during the
time period. Response to Request number seventeen. Miss Robert's objections
(06:15):
to this request on the grounds that it is overly
broad and unduly burdensome and calls for the production of
documents that are irrelevant to this action and not reasonably
calculated to lead to discovery of admissible evidence. Miss Roberts subjects,
and that it seeks information protected by the attorney client privilege,
the attorney work product privilege, joint defense, common interest privilege,
(06:38):
and any other applicable privilege. Miss Roberts subjects to this request,
and that it is overly broad, but not limited to
travel records relevant to the abuse that she suffered. Miss
Roberts subjects to this request, and that it seeks information
that is wholly irrelevant to this lawsuit. Subject to and
without waiving the above objections, Miss Roberts has already produced
(06:59):
documents and will produce non privileged documents responsive to this request,
and will continue to supplement its production per the agreements
made in the March twenty first, twenty sixteen Meet and
confer We will attempt to locate and make copies of
Plaintiff's current passport Book eighteen, all documents showing any payments
of any kind made by Jeffrey Epstein or any of
(07:22):
his agents or associates to you from nineteen ninety nine
until the present. Response to Request number eighteen, Miss Roberts
objects to this request in that the documents responsive to
this request or within the possession, custody, and control of
the defendant and Jeffrey Epstein, with whom she claims a
joint defense privilege, and defendant has refused to produce the
(07:43):
responsive documents. Miss Roberts objects in that it seeks information
protected by the attorney client privilege, the attorney work product privilege,
joint defense common interest privilege, the public interest privilege, and
any other applicable privilege. At this point in time, Miss
Roberts has been unable to locate any such documents, but
continues to search for responsive documents. Number nineteen any document
(08:09):
reflecting a confidentiality agreement, settlement agreement, or any other contractual
agreement of any kind between you and Jeffrey Epstein, or
any attorneys for you and or mister Epstein. Response to
Request number nineteen, Miss Roberts subjects to this request, and
that the documents responsive to this request are within the possession, custody,
(08:30):
and control of the defendant and Jeffrey Epstein, with whom
she claims a joint defense privilege, and defendant has refused
to produce responsive documents. Miss Roberts objects in that it
seeks information protected by the attorney client privilege, the attorney
work product privilege, joint defense common interest privilege, the public
interest privilege, and any other applicable privilege. Miss Roberts is
(08:53):
in possession of a responsive document that contains a confidentiality provision,
as discussed during the March twenty first, twenty sixteen meet
and confer. If Defendant obtains and produces to Miss Roberts
a written waiver from her co conspirator mister Epstein of
the confidentiality provision releasing Miss Roberts from any liability whatsoever
(09:15):
under the confidentiality provision, she will produce the document number
twenty any document reflecting your intent, plan, or consideration of
asserting or threatening a claim or filing a lawsuit against
another person, Any document reflecting such a claim or lawsuit,
including any complaint or a draft complaint, or any demand
(09:37):
for consideration with respect to any such claim or lawsuit
against any person. Response to Request number twenty, Miss Roberts
objections to this request on the grounds that it is
overly brought and unduly burdensome, and calls for the production
of documents that are irrelevant to this action and not
reasonably calculated to lead to the discovery of ad miss evidence.
(10:01):
Miss Roberts subjects to this request to the extent it
seeks documents protected by the attorney client, work product, joint defense,
or any other applicable privilege. Miss Roberts subjects because this
request is overly broad and unduly burdensome in that it
seeks wholly privileged communications from other cases, the logging of
which on a privileged log would be unduly burdensome. As such,
(10:24):
Miss Roberts is providing categorical privilege entries relating to the matters.
At this point in time, Miss Roberts has not found
any non privileged documents responsive to this request, but continues
to search for responsive documents. Twenty one all documents relating
to your driver's license from nineteen ninety eight to two
(10:45):
thousand and two. Response to Request number twenty one. Miss
Roberts objections to this request on the grounds that it
is overly broad and unduly burdensome, and calls for the
production of documents that are irrelevant to this action and
not reasonably calculated to lead to the discovery of admissible evidence.
Miss Roberts objects to this request and that documents responsive
(11:08):
to this request or within the possession, custody, and control
of the defendant and Jeffrey Epstein, for whom she claims
the joint defense privilege, and defendant has refused to produce
responsive documents. At this point in time, Miss Roberts has
not found any documents responsive to this request, but continues
to search for responsive documents. All right, folks, we're going
(11:30):
to wrap up right there, and in the next episode
discussing the topic, we'll pick up where we left off.
All of the information that goes with this episode can
be found in the description box. What's up, everyone, and
welcome back to the Epstein Chronicles. In this episode, we're
diving right back in to Virginia's second supplemental response and
(11:50):
a request for Discovery number twenty two, A copy of
your marriage license from nineteen ninety nine to the present.
Response to request number to tie twenty two Miss Roberts objections
to this request on the grounds that it is irrelevant
to this action and not reasonably calculated to lead to
the discovery of admissible evidence. Miss Roberts objects in that
(12:12):
it seeks information protected by the attorney client privilege, the
attorney work product privilege, and any other applicable privilege. Subject
to and without waiving the above objections, Miss Roberts has
already produced documents and will produce non privileged documents responsive
to this request, and will continue to supplement this production.
(12:32):
Twenty three All documents concerning your naturalization application to Australia
from nineteen ninety nine to the present. Response to Request
number twenty three. Miss Roberts objections to this request on
the grounds that it is irrelevant to this action and
not reasonably calculated to lead to the discovery of admissible evidence.
(12:53):
Miss Roberts objects in that it seeks information protected by
the attorney client privilege, the attorney work product privilege, and
any other applicable privilege. Miss Roberts has been unable to
locate any such documents. Twenty four All documents concerning your
employment in Australia, including but not limited to employment applications,
pay stubs documents reflecting your income, including any tax documents.
(13:18):
Response to Request number twenty four. Miss Roberts objections to
this request on the grounds that it is overly broad
and unduly burdensome, and calls for the production of documents
that are irrelevant to this action and not reasonably calculated
to lead to the discovery of admissible evidence. Miss Roberts
objects to this request in that it seeks confidential financial information.
(13:41):
Miss Roberts objects to this request to the extent it
seeks documents protected by the attorney client work product, joint defense,
or any other applicable privilege. Miss Roberts objects to this
request in that it seeks overly broad financial information not
tailored to the sexual abuse and defamation issues in this case.
Subject to and without waiving the above objections, Miss Roberts
(14:04):
has already produced documents and will produce non privileged documents
responsive to this request, and will continue to supplement this production.
Twenty five All documents concerning any massage therapist's license obtained
by you, including any massage therapy license issued in the
United States, Thailand, and or Australia. Response to Request number
(14:27):
twenty five. Miss Roberts objects to this request in that
document's responsive to this request are within the possession, custody,
and control of the defendant and Jeffrey Epstein, for whom
she claims a joint defense privilege, and defendant has refused
to produce responsive documents. Miss Roberts objects in that it
seeks information protected by the attorney client privilege, the attorney
(14:50):
work product privilege, and any other applicable privilege. At this
point in time, Miss Roberts has not found any non
privileged documents responsive to this request, but continue used to
search for responsive documents twenty six All documents concerning any
prescription drugs taken by you, including the prescribing doctor, the
(15:10):
dates of said prescription, and the dates of any fulfillment
of any such prescription Response to Request number twenty six.
Miss Robert's objections to this request on the grounds that
it is overly broad and unduly burdensome, and calls for
the production of documents that are irrelevant to this action
and not reasonably calculated to lead to the discovery of
(15:31):
admissible evidence. Miss Roberts objects to this request in that
it is not limited in the date range in any way. Therefore,
if she was on a prescription drug when she was
two years old, she would have to produce that document.
Miss Roberts also objects to this request and that it
is not limited to prescription drugs she has taken as
a result of the abuse she endured. Miss Roberts objects
(15:54):
to this request to the extent it seeks confidential medical
records that are not relevant to this action. Miss Roberts
objects to this request to the extent it seeks documents
protected by the attorney client work product or any other
applicable privilege, subject to and without waiving the above objection.
Miss Roberts has already produced documents and is producing non
(16:17):
privileged documents responsive to this request, limited to documents relating
to prescription drugs relating to her treatment for sexual abuse
she suffered at the hands of the defendant and Jeffrey Epstein,
and relating to conditions or symptoms arising after defendants defamatory statement,
and will continue to supplement this production. Twenty seven all
(16:38):
documents written or recorded which reference by name or other
description Glain Maxwell. Response to Request number twenty seven. Miss
Roberts objects in that it seeks information protected by the
attorney client privilege, the attorney work product privilege, joint Defense,
common interest privilege, the public interest privilege, and any other
(16:59):
applicationable privilege. Miss Roberts subjects to this request to the
extent it seeks proprietary or copyrighted protected materials, subject to
and without waiving the above objections. Miss Roberts has already
produced documents and will produce non privileged documents responsive to
this request, and will continue to supplement her production. Twenty eight.
(17:22):
All documents are reflecting notes of or notes prepared for,
any statements or interviews in which you referenced by name
or other description. Glaine Maxwell response to request number twenty eight.
Miss Roberts subjects in that it seeks information protected by
the attorney client privilege, the attorney work product privilege, joint
(17:42):
Defense common interest privilege, the public interest privilege, and any
other applicable privilege. Miss Roberts subjects to this request to
the extent it seeks proprietary or copyright protected materials. At
this point in time, Miss Roberts has not found any
non privileged documents responsive to this request, but continues to
search for responsive documents. Twenty nine All documents concerning any
(18:07):
communications by you or on your behalf with any media outlet,
including but not limited to, The Daily Mail, Daily Express,
The Mirror, National Inquirer, New York Daily News, Radar Online,
and The New York Post, whether or not such communications
were on the record or off the record. Response to
Request number twenty nine, Miss Roberts objects in that it
(18:30):
seeks information protected by the attorney client privilege, the attorney
work product privilege, and any other applicable privilege. Miss Roberts
objects to this request to the extent it seeks proprietary
or copyright protected materials subject to and without waiving the
above objections. Miss Roberts has already produced documents and will
(18:51):
continue to produce non privileged documents responsive to this request,
and will continue to supplement her production thirty all documents.
It's concerning any income received by you from any media
outlet in exchange for your statements, whether on the record
or off the record, regarding Jeffrey Epstein, Alan M. Dershowitz,
Prince Andrew, Bill Clinton, or Glenn Maxwell, or any of
(19:14):
the individuals identified by you in response to interrogatory numbers
eight through fourteen. Response to Request number thirty, Miss Roberts
objects in that it seeks information protected by the attorney
client privilege, the attorney work product privilege, and any other
applicable privilege. Miss Roberts subjects to this request to the
extent it seeks proprietary or copyright protected materials. Miss Roberts
(19:39):
subjects to this request and that it seeks confidential financial
information subject to and without waiving the above objections. Miss
Roberts has already produced documents and will continue to produce
non privileged documents responsive to this request, and will continue
to supplement her production thirty one all documents concerning any
(20:00):
the actual or potential book, television, or a movie deals
concerning your allegations about being a sex slave, including but
not limited to, a potential book by former New York
Police detective John Connolly and writer James Patterson. Response to
Request number thirty one, Miss Roberts objects in that it
seeks information protected by the attorney client privilege, the attorney
(20:23):
work product privilege, and any other applicable privilege. Miss Roberts
objects to this request to the extent it seeks proprietary
or copyrighted materials. Miss Roberts objects to this request in
that it seeks confidential financial information, subject to and without
waiving the objections. Miss Roberts has already produced documents and
(20:44):
will produce non privileged documents responsive to this request, and
will continue to supplement her production Number thirty two. All
manuscripts and or other writings, whether published or unpublished, created
in whole or in part by, or in consultation with you,
concerning relating or referring to Jeffrey Epstein, Glenn Maxwell, or
(21:05):
any of their agents or associates. Response to Request number
thirty two, Miss Roberts objects in that it seeks information
protected by the attorney client privilege, the attorney work product privilege,
and any other applicable privilege. Miss Roberts objects to this
request to the extent it seeks proprietary or copyright protected materials.
(21:26):
Miss Roberts subjects to this request and that it seeks
confidential financial information subject to and without waiving the above objections.
Miss Roberts has already produced documents and will produce non
privileged documents responsive to this request, and will continue to
supplement her production. Thirty three. All documents concerning or relating
(21:47):
to victims. Refuse silence the organization referred to in the complaint,
including articles of incorporation, any financial records for the organization,
any income you have received from the organization, and any
Dotcom documents reflecting your role within the organization or any
acts taken on behalf of the organization. Response to Request
(22:08):
number thirty three, Miss Roberts objects in that it seeks
information protected by the attorney client privilege, the attorney work
product privilege, and any other applicable privilege. Miss Roberts objects
to this request to the extent it seeks proprietary or
copyright protected materials. Miss Roberts objects to this request and
that it seeks confidential financial information subject to and without
(22:32):
waiving the above objections. Miss Roberts has already produced documents
and will produce non privileged documents responsive to this request,
and will continue to supplement her production thirty four to
the extent not produced in response to the above listed
requested documents all notes, writings, photographs, and or audio or
(22:53):
video recordings made or recorded by you or of you
at any time that refer or relate in any way
to Glaige Maxwell. Response to Request number thirty four, Miss
Roberts objects to this request and that the documents responsive
to this request are in the possession, custody, and control
of the defendant and Jeffrey Epstein, for whom she claims
(23:14):
a joint defense privilege, and defendant has refused to produce
responsive documents. Miss Roberts objects that it seeks information protected
by the attorney client privilege, the attorney work product privilege,
and any other applicable privilege. Miss Roberts objects to this
request to the extent it seeks proprietary and copyrighted protected material,
(23:35):
subject to and without waiving the above objections. Miss Roberts
has already produced documents and will produce non privileged documents
responsive to this request, and will continue to supplement her
production thirty five All phone records, including text messages, emails,
social media communications, letters, or any other form of communication
(23:56):
from you or to you or associated with you in
any from nineteen ninety eight to the present which concern
relate to identify, mention, or reflect Klain, Maxwell, Jeffrey Epstein,
Alan Dershowitz, Prince Andrew, Bill Clinton, or any of the
individuals identified in response to Interrogatories number eight and fourteen.
(24:18):
Response to Request number thirty five, Miss Roberts objections to
this request on the grounds that it is overly broad
and unduly burdensome and calls for the production of documents
that are irrelevant to the action and not reasonably calculated
to lead to the discovery of admissible evidence. Miss Roberts
subjects to this request to the extent it seeks documents
(24:40):
from anyone associated with you, as that is vague and ambiguous.
Miss Roberts objects to this request and that documents responsive
to this request are within the possession, custody, and control
of the defendant and Jeffrey Epstein, for whom she claims
the joint defense privilege, and defendant has refused to produce
response of documents. Miss Roberts subjects in that it seeks
(25:03):
information protected by the attorney client privilege, the attorney work
product privilege, and public interest privilege, and any other applicable privilege.
Miss Roberts objects to this request to the extent it
seeks proprietary and copyright protected material, subject to and without
waiving the above objections. Miss Roberts has already produced documents
(25:24):
and will produce non privileged documents responsive to this request,
and will continue to supplement her production while Miss Roberts
has produced her documents. Miss Roberts's response does not include
documents from anyone associated with you based on the above
referenced Objection thirty six all documents relating to massages, including,
(25:44):
but not limited to, any documents reflecting the recruiting or
hiring of messuses, advertising for messuses, flyers created for distribution
at high schools or colleges, and records reflecting emails or
calls to persons relating to masages. Response to Request number
thirty six. Miss Robert's objections to this request on the
(26:07):
grounds that is overly broad and unduly burdensome and calls
for the production of documents that are irrelevant to this
action and not reasonably calculated to lead to the discovery
of admissible evidence. Miss Roberts objects to this request and
that it is not time limited in any way. Miss
Roberts objects to this request and that documents responsive to
(26:28):
this request are within the possession, custody, and control of
the defendant and Jeffrey Epstein, for whom she claims a
joint defense privilege, and defendant has refused to produce responsive documents.
Miss Roberts objects in that it seeks information protected by
the attorney client privilege, the attorney work product privilege, public
interest privilege, and any other applicable privilege. Miss Roberts has
(26:52):
been unable to locate such documents thirty seven statements or
records from any bank into which you deposited money, read
from Jeffrey Epstein, any person identified in Interrogatory number eight
or fourteen, any witness disclosed in your Rule twenty six
A disclosures, any media organization, or any employee or affiliate
(27:13):
of any media organization. Response to Request number thirty seven,
Miss Roberts subjects in that it seeks information protected by
the attorney client privilege, the attorney work product privilege, joint defense,
common interest privilege, the public interest privilege, and any other
applicable privilege. Miss Roberts objects to this request, and that
it seeks personal financial information. Miss Roberts objects to this
(27:36):
request and that it is overly broad and has no
time limitation. Subject to and without waiving the objections, Miss
Roberts has already produced documents and will produce non privileged
documents responsive to this request, and will continue to supplement
her production. This was signed by Sigared McAuley and it
(27:56):
was dated April twenty ninth, twenty sixteen. All Right, folks,
that's another document in the books and there's certainly more
to come. All of the information that goes with this
episode can be found in the description box.
What's up everyone, and welcome back to the Epstein Chronicles.
In this episode, we're going to pick right back up
where we left off with the Virginia Roberts' second supplemental
response number eleven. Any document reflecting any confidentiality agreement by
in between or concerning you and the mar A Lago
(00:21):
Club response to Requests number ten. Miss Roberts subjects to
this request to the extent it seeks documents protected by
the attorney client, work product, joint defense, public interest, and
any other applicable privilege. Miss Roberts has been unable to
locate any such documents. Twelve. All documents concerning any employment
(00:43):
by you from nineteen ninety eight to the present, or
identified by you in response to interrogatory number nine, including
any records of your employment at the Roadhouse Grille in
Palm Beach, Florida. Response to Request number twelve. Miss Roberts
objections to this request on the grounds that is overly
broad and unduly burdensome and calls for the production of
(01:05):
documents that are irrelevant to this action and not reasonably
calculated to lead to the discovery of admissible evidence. Miss
Roberts objects to this request to the extent it seeks
documents protected by the attorney client work product, joint defense,
public interest, or any other applicable privilege, subject to and
without waiving the above objections. Miss Roberts has already produced
(01:28):
documents and will produce non privileged documents responsive to this request,
and will continue to supplement this production. Thirteen all documents
concerning any allegations of theft by you from the Roadhouse
Grille in Palm Beach, Florida from nineteen ninety nine to
two thousand and two. Response to Requests number thirteen. Miss
(01:49):
Roberts objects to this request and that it seeks information
solely to harass, embarrass, and intimidate Miss Roberts. Miss Roberts
objects to this request to the extent it seeks docus
mints protected by the attorney client privilege, the attorney work
product privilege, joint defense, common interest privilege, public interest privilege,
and any other applicable privilege. Miss Roberts objects to this
(02:12):
request and that it wrongfully characterizes a theft by you.
Miss Roberts objects to this request as it seeks documents
of sealed juvenile records, and only means of obtaining such
records are either through the court order or illegal means.
Miss Roberts has been unable to locate any such documents.
Fourteen A copy of your federal, state, or local tax
(02:34):
returns for the years nineteen ninety eight to the present,
whether from the United States or any other country. Response
to Request number fourteen. Miss Roberts objections to this request
on the grounds that it is overly broad and unduly burdensome,
and calls for the production of documents that are irrelevant
to this action and not reasonably calculated to lead to
(02:58):
the discovery of admissible vas evidence. Miss Roberts objects to
this request and that it seeks confidential financial information and
that is irrelevant to this action. Miss Roberts objects to
this request and that it seeks financial information from her
when she was a minor child starting at age fourteen.
Miss Roberts objects in that it seeks information protected by
(03:19):
the attorney client privilege, the attorney work product privilege, joint
defense common interest privilege, the account in client privilege, and
any other applicable privilege. Subject to and without waiving the
above objections, Miss Roberts has already produced documents and will
produce non privileged documents responsive to this request and will
continue to supplement its production. Fifteen all documents concerning your
(03:43):
attendance at, or enrollment in any school or educational program
of whatever type from nineteen ninety eight to the present.
Response to Request number fifteen, Miss Roberts objections to this
request on the grounds that it is overly broad and
on duly burdensome, and calls for the production of documents
that are irrelevant to this action and not reasonably calculated
(04:06):
to lead to the discovery of admissible evidence. Miss Roberts
objects to this request to the extent it seeks documents
protected by the attorney client privilege, the attorney work product privilege,
joint defense, common interest privilege, and public interest privilege, and
any other applicable privilege. Miss Roberts objects to this request
in that her school records from when she was a
(04:28):
minor child are an invasion of privacy and sought only
to harass an embarrasser. Subject to and without waiving the
above objections, Miss Roberts has already produced documents and will
produce non privileged documents responsive to this request, and will
continue to supplement its production. Sixteen Any diary, journal or
(04:49):
calendar concerning your activities between nineteen ninety six and two
thousand and two response to Requests Number sixteen. Miss Roberts
objection to this request on the grounds that the time
period is overly broad and calls for the production of
documents that are irrelevant to this action and not reasonably
calculated to lead to the discovery of admissible evidence. Miss
(05:13):
Roberts objects to this request to the extent it seeks
proprietary and copyrighted protected materials. Miss Roberts subjects in that
it seeks information protected by the attorney client privilege, the
attorney work product privilege, joint defense common interest privilege, and
any other applicable privilege. Miss Roberts objects to this request
(05:33):
in that it seeks highly personal and sensitive material from
a time when she was being sexually trafficked. Miss Roberts
has been unable to locate any such documents. Seventeen. All
documents relating to your travel from the period of nineteen
ninety eight to the present, including but not limited to,
a copy of your passport that was valid for any
(05:54):
part of that time period, any visa issue to you
for travel, any visa application that you prepare or which
was prepared on your behalf and travel itinerary receipt log
or document, including any photograph substantiating your travel during the
time period. Response to Request number seventeen. Miss Robert's objections
(06:15):
to this request on the grounds that it is overly
broad and unduly burdensome and calls for the production of
documents that are irrelevant to this action and not reasonably
calculated to lead to discovery of admissible evidence. Miss Roberts subjects,
and that it seeks information protected by the attorney client privilege,
the attorney work product privilege, joint defense, common interest privilege,
(06:38):
and any other applicable privilege. Miss Roberts subjects to this request,
and that it is overly broad, but not limited to
travel records relevant to the abuse that she suffered. Miss
Roberts subjects to this request, and that it seeks information
that is wholly irrelevant to this lawsuit. Subject to and
without waiving the above objections, Miss Roberts has already produced
(06:59):
documents and will produce non privileged documents responsive to this request,
and will continue to supplement its production per the agreements
made in the March twenty first, twenty sixteen Meet and
confer We will attempt to locate and make copies of
Plaintiff's current passport Book eighteen, all documents showing any payments
of any kind made by Jeffrey Epstein or any of
(07:22):
his agents or associates to you from nineteen ninety nine
until the present. Response to Request number eighteen, Miss Roberts
objects to this request in that the documents responsive to
this request or within the possession, custody, and control of
the defendant and Jeffrey Epstein, with whom she claims a
joint defense privilege, and defendant has refused to produce the
(07:43):
responsive documents. Miss Roberts objects in that it seeks information
protected by the attorney client privilege, the attorney work product privilege,
joint defense common interest privilege, the public interest privilege, and
any other applicable privilege. At this point in time, Miss
Roberts has been unable to locate any such documents, but
continues to search for responsive documents. Number nineteen any document
(08:09):
reflecting a confidentiality agreement, settlement agreement, or any other contractual
agreement of any kind between you and Jeffrey Epstein, or
any attorneys for you and or mister Epstein. Response to
Request number nineteen, Miss Roberts subjects to this request, and
that the documents responsive to this request are within the possession, custody,
(08:30):
and control of the defendant and Jeffrey Epstein, with whom
she claims a joint defense privilege, and defendant has refused
to produce responsive documents. Miss Roberts objects in that it
seeks information protected by the attorney client privilege, the attorney
work product privilege, joint defense common interest privilege, the public
interest privilege, and any other applicable privilege. Miss Roberts is
(08:53):
in possession of a responsive document that contains a confidentiality provision,
as discussed during the March twenty first, twenty sixteen meet
and confer. If Defendant obtains and produces to Miss Roberts
a written waiver from her co conspirator mister Epstein of
the confidentiality provision releasing Miss Roberts from any liability whatsoever
(09:15):
under the confidentiality provision, she will produce the document number
twenty any document reflecting your intent, plan, or consideration of
asserting or threatening a claim or filing a lawsuit against
another person, Any document reflecting such a claim or lawsuit,
including any complaint or a draft complaint, or any demand
(09:37):
for consideration with respect to any such claim or lawsuit
against any person. Response to Request number twenty, Miss Roberts
objections to this request on the grounds that it is
overly brought and unduly burdensome, and calls for the production
of documents that are irrelevant to this action and not
reasonably calculated to lead to the discovery of ad miss evidence.
(10:01):
Miss Roberts subjects to this request to the extent it
seeks documents protected by the attorney client, work product, joint defense,
or any other applicable privilege. Miss Roberts subjects because this
request is overly broad and unduly burdensome in that it
seeks wholly privileged communications from other cases, the logging of
which on a privileged log would be unduly burdensome. As such,
(10:24):
Miss Roberts is providing categorical privilege entries relating to the matters.
At this point in time, Miss Roberts has not found
any non privileged documents responsive to this request, but continues
to search for responsive documents. Twenty one all documents relating
to your driver's license from nineteen ninety eight to two
(10:45):
thousand and two. Response to Request number twenty one. Miss
Roberts objections to this request on the grounds that it
is overly broad and unduly burdensome, and calls for the
production of documents that are irrelevant to this action and
not reasonably calculated to lead to the discovery of admissible evidence.
Miss Roberts objects to this request and that documents responsive
(11:08):
to this request or within the possession, custody, and control
of the defendant and Jeffrey Epstein, for whom she claims
the joint defense privilege, and defendant has refused to produce
responsive documents. At this point in time, Miss Roberts has
not found any documents responsive to this request, but continues
to search for responsive documents. All right, folks, we're going
(11:30):
to wrap up right there, and in the next episode
discussing the topic, we'll pick up where we left off.
All of the information that goes with this episode can
be found in the description box. What's up, everyone, and
welcome back to the Epstein Chronicles. In this episode, we're
diving right back in to Virginia's second supplemental response and
(11:50):
a request for Discovery number twenty two, A copy of
your marriage license from nineteen ninety nine to the present.
Response to request number to tie twenty two Miss Roberts objections
to this request on the grounds that it is irrelevant
to this action and not reasonably calculated to lead to
the discovery of admissible evidence. Miss Roberts objects in that
(12:12):
it seeks information protected by the attorney client privilege, the
attorney work product privilege, and any other applicable privilege. Subject
to and without waiving the above objections, Miss Roberts has
already produced documents and will produce non privileged documents responsive
to this request, and will continue to supplement this production.
(12:32):
Twenty three All documents concerning your naturalization application to Australia
from nineteen ninety nine to the present. Response to Request
number twenty three. Miss Roberts objections to this request on
the grounds that it is irrelevant to this action and
not reasonably calculated to lead to the discovery of admissible evidence.
(12:53):
Miss Roberts objects in that it seeks information protected by
the attorney client privilege, the attorney work product privilege, and
any other applicable privilege. Miss Roberts has been unable to
locate any such documents. Twenty four All documents concerning your
employment in Australia, including but not limited to employment applications,
pay stubs documents reflecting your income, including any tax documents.
(13:18):
Response to Request number twenty four. Miss Roberts objections to
this request on the grounds that it is overly broad
and unduly burdensome, and calls for the production of documents
that are irrelevant to this action and not reasonably calculated
to lead to the discovery of admissible evidence. Miss Roberts
objects to this request in that it seeks confidential financial information.
(13:41):
Miss Roberts objects to this request to the extent it
seeks documents protected by the attorney client work product, joint defense,
or any other applicable privilege. Miss Roberts objects to this
request in that it seeks overly broad financial information not
tailored to the sexual abuse and defamation issues in this case.
Subject to and without waiving the above objections, Miss Roberts
(14:04):
has already produced documents and will produce non privileged documents
responsive to this request, and will continue to supplement this production.
Twenty five All documents concerning any massage therapist's license obtained
by you, including any massage therapy license issued in the
United States, Thailand, and or Australia. Response to Request number
(14:27):
twenty five. Miss Roberts objects to this request in that
document's responsive to this request are within the possession, custody,
and control of the defendant and Jeffrey Epstein, for whom
she claims a joint defense privilege, and defendant has refused
to produce responsive documents. Miss Roberts objects in that it
seeks information protected by the attorney client privilege, the attorney
(14:50):
work product privilege, and any other applicable privilege. At this
point in time, Miss Roberts has not found any non
privileged documents responsive to this request, but continue used to
search for responsive documents twenty six All documents concerning any
prescription drugs taken by you, including the prescribing doctor, the
(15:10):
dates of said prescription, and the dates of any fulfillment
of any such prescription Response to Request number twenty six.
Miss Robert's objections to this request on the grounds that
it is overly broad and unduly burdensome, and calls for
the production of documents that are irrelevant to this action
and not reasonably calculated to lead to the discovery of
(15:31):
admissible evidence. Miss Roberts objects to this request in that
it is not limited in the date range in any way. Therefore,
if she was on a prescription drug when she was
two years old, she would have to produce that document.
Miss Roberts also objects to this request and that it
is not limited to prescription drugs she has taken as
a result of the abuse she endured. Miss Roberts objects
(15:54):
to this request to the extent it seeks confidential medical
records that are not relevant to this action. Miss Roberts
objects to this request to the extent it seeks documents
protected by the attorney client work product or any other
applicable privilege, subject to and without waiving the above objection.
Miss Roberts has already produced documents and is producing non
(16:17):
privileged documents responsive to this request, limited to documents relating
to prescription drugs relating to her treatment for sexual abuse
she suffered at the hands of the defendant and Jeffrey Epstein,
and relating to conditions or symptoms arising after defendants defamatory statement,
and will continue to supplement this production. Twenty seven all
(16:38):
documents written or recorded which reference by name or other
description Glain Maxwell. Response to Request number twenty seven. Miss
Roberts objects in that it seeks information protected by the
attorney client privilege, the attorney work product privilege, joint Defense,
common interest privilege, the public interest privilege, and any other
(16:59):
applicationable privilege. Miss Roberts subjects to this request to the
extent it seeks proprietary or copyrighted protected materials, subject to
and without waiving the above objections. Miss Roberts has already
produced documents and will produce non privileged documents responsive to
this request, and will continue to supplement her production. Twenty eight.
(17:22):
All documents are reflecting notes of or notes prepared for,
any statements or interviews in which you referenced by name
or other description. Glaine Maxwell response to request number twenty eight.
Miss Roberts subjects in that it seeks information protected by
the attorney client privilege, the attorney work product privilege, joint
(17:42):
Defense common interest privilege, the public interest privilege, and any
other applicable privilege. Miss Roberts subjects to this request to
the extent it seeks proprietary or copyright protected materials. At
this point in time, Miss Roberts has not found any
non privileged documents responsive to this request, but continues to
search for responsive documents. Twenty nine All documents concerning any
(18:07):
communications by you or on your behalf with any media outlet,
including but not limited to, The Daily Mail, Daily Express,
The Mirror, National Inquirer, New York Daily News, Radar Online,
and The New York Post, whether or not such communications
were on the record or off the record. Response to
Request number twenty nine, Miss Roberts objects in that it
(18:30):
seeks information protected by the attorney client privilege, the attorney
work product privilege, and any other applicable privilege. Miss Roberts
objects to this request to the extent it seeks proprietary
or copyright protected materials subject to and without waiving the
above objections. Miss Roberts has already produced documents and will
(18:51):
continue to produce non privileged documents responsive to this request,
and will continue to supplement her production thirty all documents.
It's concerning any income received by you from any media
outlet in exchange for your statements, whether on the record
or off the record, regarding Jeffrey Epstein, Alan M. Dershowitz,
Prince Andrew, Bill Clinton, or Glenn Maxwell, or any of
(19:14):
the individuals identified by you in response to interrogatory numbers
eight through fourteen. Response to Request number thirty, Miss Roberts
objects in that it seeks information protected by the attorney
client privilege, the attorney work product privilege, and any other
applicable privilege. Miss Roberts subjects to this request to the
extent it seeks proprietary or copyright protected materials. Miss Roberts
(19:39):
subjects to this request and that it seeks confidential financial
information subject to and without waiving the above objections. Miss
Roberts has already produced documents and will continue to produce
non privileged documents responsive to this request, and will continue
to supplement her production thirty one all documents concerning any
(20:00):
the actual or potential book, television, or a movie deals
concerning your allegations about being a sex slave, including but
not limited to, a potential book by former New York
Police detective John Connolly and writer James Patterson. Response to
Request number thirty one, Miss Roberts objects in that it
seeks information protected by the attorney client privilege, the attorney
(20:23):
work product privilege, and any other applicable privilege. Miss Roberts
objects to this request to the extent it seeks proprietary
or copyrighted materials. Miss Roberts objects to this request in
that it seeks confidential financial information, subject to and without
waiving the objections. Miss Roberts has already produced documents and
(20:44):
will produce non privileged documents responsive to this request, and
will continue to supplement her production Number thirty two. All
manuscripts and or other writings, whether published or unpublished, created
in whole or in part by, or in consultation with you,
concerning relating or referring to Jeffrey Epstein, Glenn Maxwell, or
(21:05):
any of their agents or associates. Response to Request number
thirty two, Miss Roberts objects in that it seeks information
protected by the attorney client privilege, the attorney work product privilege,
and any other applicable privilege. Miss Roberts objects to this
request to the extent it seeks proprietary or copyright protected materials.
(21:26):
Miss Roberts subjects to this request and that it seeks
confidential financial information subject to and without waiving the above objections.
Miss Roberts has already produced documents and will produce non
privileged documents responsive to this request, and will continue to
supplement her production. Thirty three. All documents concerning or relating
(21:47):
to victims. Refuse silence the organization referred to in the complaint,
including articles of incorporation, any financial records for the organization,
any income you have received from the organization, and any
Dotcom documents reflecting your role within the organization or any
acts taken on behalf of the organization. Response to Request
(22:08):
number thirty three, Miss Roberts objects in that it seeks
information protected by the attorney client privilege, the attorney work
product privilege, and any other applicable privilege. Miss Roberts objects
to this request to the extent it seeks proprietary or
copyright protected materials. Miss Roberts objects to this request and
that it seeks confidential financial information subject to and without
(22:32):
waiving the above objections. Miss Roberts has already produced documents
and will produce non privileged documents responsive to this request,
and will continue to supplement her production thirty four to
the extent not produced in response to the above listed
requested documents all notes, writings, photographs, and or audio or
(22:53):
video recordings made or recorded by you or of you
at any time that refer or relate in any way
to Glaige Maxwell. Response to Request number thirty four, Miss
Roberts objects to this request and that the documents responsive
to this request are in the possession, custody, and control
of the defendant and Jeffrey Epstein, for whom she claims
(23:14):
a joint defense privilege, and defendant has refused to produce
responsive documents. Miss Roberts objects that it seeks information protected
by the attorney client privilege, the attorney work product privilege,
and any other applicable privilege. Miss Roberts objects to this
request to the extent it seeks proprietary and copyrighted protected material,
(23:35):
subject to and without waiving the above objections. Miss Roberts
has already produced documents and will produce non privileged documents
responsive to this request, and will continue to supplement her
production thirty five All phone records, including text messages, emails,
social media communications, letters, or any other form of communication
(23:56):
from you or to you or associated with you in
any from nineteen ninety eight to the present which concern
relate to identify, mention, or reflect Klain, Maxwell, Jeffrey Epstein,
Alan Dershowitz, Prince Andrew, Bill Clinton, or any of the
individuals identified in response to Interrogatories number eight and fourteen.
(24:18):
Response to Request number thirty five, Miss Roberts objections to
this request on the grounds that it is overly broad
and unduly burdensome and calls for the production of documents
that are irrelevant to the action and not reasonably calculated
to lead to the discovery of admissible evidence. Miss Roberts
subjects to this request to the extent it seeks documents
(24:40):
from anyone associated with you, as that is vague and ambiguous.
Miss Roberts objects to this request and that documents responsive
to this request are within the possession, custody, and control
of the defendant and Jeffrey Epstein, for whom she claims
the joint defense privilege, and defendant has refused to produce
response of documents. Miss Roberts subjects in that it seeks
(25:03):
information protected by the attorney client privilege, the attorney work
product privilege, and public interest privilege, and any other applicable privilege.
Miss Roberts objects to this request to the extent it
seeks proprietary and copyright protected material, subject to and without
waiving the above objections. Miss Roberts has already produced documents
(25:24):
and will produce non privileged documents responsive to this request,
and will continue to supplement her production while Miss Roberts
has produced her documents. Miss Roberts's response does not include
documents from anyone associated with you based on the above
referenced Objection thirty six all documents relating to massages, including,
(25:44):
but not limited to, any documents reflecting the recruiting or
hiring of messuses, advertising for messuses, flyers created for distribution
at high schools or colleges, and records reflecting emails or
calls to persons relating to masages. Response to Request number
thirty six. Miss Robert's objections to this request on the
(26:07):
grounds that is overly broad and unduly burdensome and calls
for the production of documents that are irrelevant to this
action and not reasonably calculated to lead to the discovery
of admissible evidence. Miss Roberts objects to this request and
that it is not time limited in any way. Miss
Roberts objects to this request and that documents responsive to
(26:28):
this request are within the possession, custody, and control of
the defendant and Jeffrey Epstein, for whom she claims a
joint defense privilege, and defendant has refused to produce responsive documents.
Miss Roberts objects in that it seeks information protected by
the attorney client privilege, the attorney work product privilege, public
interest privilege, and any other applicable privilege. Miss Roberts has
(26:52):
been unable to locate such documents thirty seven statements or
records from any bank into which you deposited money, read
from Jeffrey Epstein, any person identified in Interrogatory number eight
or fourteen, any witness disclosed in your Rule twenty six
A disclosures, any media organization, or any employee or affiliate
(27:13):
of any media organization. Response to Request number thirty seven,
Miss Roberts subjects in that it seeks information protected by
the attorney client privilege, the attorney work product privilege, joint defense,
common interest privilege, the public interest privilege, and any other
applicable privilege. Miss Roberts objects to this request, and that
it seeks personal financial information. Miss Roberts objects to this
(27:36):
request and that it is overly broad and has no
time limitation. Subject to and without waiving the objections, Miss
Roberts has already produced documents and will produce non privileged
documents responsive to this request, and will continue to supplement
her production. This was signed by Sigared McAuley and it
(27:56):
was dated April twenty ninth, twenty sixteen. All Right, folks,
that's another document in the books and there's certainly more
to come. All of the information that goes with this
episode can be found in the description box.
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